SDGT-9966 (Blocking Memorandum)

Date issued: Apr. 11 2017

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TURBOFAC Commentary (107 words)

Notes:

1) This Blocking Memorandum relates to the litigation discussed in the comments to Case No. SDGT-2017-344570-1. It is notable, especially in the context of the litigation, for the likelihood that it represents a use of OFAC’s “blocking during the pendency of an investigation” authority that is not apparent from the regulations. More specifically, it appears as though the funds as issue were blocked pending a resolution of an investigation into whether a given entity qualifies as a SDGT, where the identity of the person under investigation was being kept secret pending the completion of the investigation. See additional commentary at section IV of General Note on the Blocking of Persons and Property Pending Investigation.